Section 704 / TCA

See attached file(s) Katie Webb, QuantaX Technology HHS-OASH-2026-0397 HHS must act now to reduce unnecessary wireless radiation exposure and protect biological fidelity: the precision with which living systems develop, regulate energy and information, repair damage, and recover. I support and present John Coates's complete comment, included in the attached PDF with my position statement and our illustrated plausible pathways. Low-fidelity biology is the upstream vulnerability HHS must investigate and prevent. Mistimed calcium signals, mitochondrial and redox mismatch, impaired repair, and persistent compensation can reduce the reserve needed for healthy development and later challenges. The S4–Mito–Spin framework connects these processes through specific molecular targets and measurable functions. A standard based on average absorbed energy cannot, by that number alone, characterize biological timing, recovery, or developmental susceptibility. The cancer evidence demands action. NTP and the Ramazzini Institute reported malignant heart schwannomas in male rats. The WHO-commissioned animal review rated evidence for increased glioma and heart schwannoma as high certainty. Melnick and Moskowitz (2026), applying EPA risk-assessment methods, calculated that the public whole-body limit is 15–900 times above modeled exposure levels for one additional cancer per 100,000 people, depending on daily exposure duration, and 8–24 times above their male-reproductive protection estimates. HHS and EPA must derive health-based limits and reduce avoidable exposure while completing that assessment. Put the Yale developmental findings at the center. Aldad and colleagues found hyperactivity, impaired memory, and altered prefrontal-cortex synaptic transmission in mice exposed prenatally to cellular-phone radiation. Yale's senior author described the experiment as showing that prenatal cell-phone exposure caused ADHD-like behavioral problems in mice. Cakir and colleagues subsequently identified delayed radial-glial differentiation and BET-mediated developmental effects in human cortical organoids. A developing child gets one chance at each developmental window. HHS must respond with prenatal protection and a funded developmental research program. Test the full pathway. Measure the S4/channel and CYB5B interfaces, calcium timing, mitochondrial reserve, spin-sensitive chemistry, chromatin responses, and later function together. Kim and colleagues' CYB5B gene-switch study identifies a molecular route from a defined field to rhythmic calcium-dependent gene regulation. The CACNA1C sleep study identifies genotype-dependent response. Use sham, carrier-only, and pulsed exposures at matched SAR with temperature control, then apply molecular blocking, rescue, and timed replay to establish the sequence. Protect future generations now. RF experiments already warrant offspring follow-up: Yan and colleagues reported sex-specific offspring growth and metabolic changes after paternal RF exposure. Separate diet and toxicant experiments demonstrate molecular transmission through sperm RNA and persistence of environmental effects across generations. HHS must directly test RF-associated germline transmission, following maternal gestational lines through F3 and paternal preconception lines through F2, with unexposed descendants and molecular mediation tests. Also measure repeated direct exposure across successive pregnancies. Continued exposure and inherited effects are distinct routes that both require investigation and prevention. My requests are concrete: 1. Publish a federal quantitative RF risk assessment using current cancer and reproductive evidence and established EPA methods. 2. Restore sustained NTP research, independent replication, prospective pregnancy cohorts, and multigenerational studies linked to early fidelity measurements. 3. Reduce unnecessary exposure in pregnancy, childcare, schools, healthcare, and sleeping environments. Fund practical wired and optical alternatives. 4. Require realistic body-contact testing and disclosure of test distance, dose averaging, active radios, and waveform conditions. 5. Reinvigorate Public Law 90-602. Ask Congress to place RF health-protection standards under HHS/EPA and repeal Section 704's health-based siting restriction. 6. Advance the Clean Ether Act through interoperable optical networks, wired-first procurement, independently evaluated pilots, and measured reductions in unnecessary transmissions. Publish a ninety-day work plan, a one-year assessment and research program, named responsible officials, and annual results. The accompanying 5,000-word statement, pathway images, and John Coates's complete comment provide the evidence and implementation requests. Protect biological fidelity before the developmental window closes. Katie Webb QuantaX Technology

My name is Dr. Marion Van Horn. I am a neuroscientist and mother of three. I am submitting this comment because I believe there is an urgent need to reassess whether the Federal Communications Commission’s (FCC) radiofrequency (RF) exposure limits adequately protect human health and the environment. This issue recently came to our attention when our friend Alison Morrow Westover tried to stop a cell tower from being installed in her neighbour’s backyard. What surprised us most was learning that, under the Telecommunications Act of 1996, health concerns cannot be used as grounds to reject a proposed cell tower, provided it complies with FCC exposure limits. But I was shocked to learn that the FCC’s RF exposure limits haven’t been substantially updated in nearly 30 years, despite ongoing scientific research in this area! As a neuroscientist who has studied brain development, I know that early-life environmental exposures can profoundly influence the developing brain. These are critical periods of development, during which environmental influences can have lasting consequences. While the long-term health effects of RF exposure remain an active area of scientific investigation, parents are absolutely justified in asking questions about the safety of placing a cell tower so close to where their children are growing up. Given the evolving scientific evidence, I believe it is essential that the FCC undertake a thorough, independent review of its exposure limits, with particular attention to long-term exposure, children’s developing nervous systems, and potential environmental effects. We should not have to wait for conclusive evidence of harm before asking whether our existing safety standards are sufficiently protective.

YESSSS!! Please, i plead with you all to investigate & update the 1986 Telecommunications Act for the sake of our children and all future generations.

I am writing to ask that HHS to adopt RF exposure limits that are protective of human health and the environment. Current exposure limits must be updated. I also ask that Section 704 of the TCA be amended to allow our local governing authorities the ability to consider this important factor when deciding on the future of our neighborhoods. The world’s biggest insurance companies like Swiss Re have EMF exclusions in their policies because they understand the risks of wireless radiation exposure. Environmental Health Sciences discusses this liability shield: “Major insurers rank radiofrequency (RF) radiation emitted by cell towers as a “high-risk” liability, often comparing the issue to asbestos or lead. The Swiss Re Institute, a leading authority in reinsurance, has categorized 5G as an “off-the-leash” risk—a designation for unpredictable threats with potentially widespread impact…Telecom companies reassure communities that cell towers are “safe,” yet they warn their shareholders of cell tower radiation-related risks in their annual reports, stating that regulations could change or legal cases could result in unfavorable rulings – which could impact their cash flow.” Our county codes, health recommendations and building permits reflect the HHS policies that date back decades. It is time to update policies with the known science of EMF / RF radiation harm.

The following information is my personal experiences from EMF's and other wireless technologies. On January 19,2018 I returned home after an appointment. My husband told me that a smart meter had been installed on our home. That night I couldn't sleep anywhere in the house. My reaction also included significant tingling, feeling anxious, weakness all over, balance was off, eyes very sensitive to light and thinking skills were off also. I felt miserable and didn't know what to do to get relief. Duke energy did replace the meter with an electrical mechanical meter, but I felt no improvement. With the previous analog meter I could function well. I had to search and educate myself about the EMF problem. Through many months I purchased products that proved to be useless. Finally, in February 2019 I learned about a product that was a filter to be attached to the circuit breaker box. I immediately ordered it and had electricians install it. While they were connecting the wires downstairs, I remained upstairs. I knew INSTANTLY when it was connected. My tingling abruptly completely stopped! After 13 months I had relief! Living with EMF sensitives has negatively impacted my health and life activities. I always need to be aware of EMF exposure sources and avoid them. Some of the hardest places have been hospitals, long term care facilities and medical offices. I have even had to change doctors due to my body's reaction in those settings. With more technologies being used in my neighborhood, I needed to have a building biologist help assess my home. Using two different meters the assessment showed that I needed further remediation. Seeing actual numbers gave me a clear understanding of the exposure strength. For the future I strongly support the 704NoMore initiatives. New lower exposure standards need to be implemented based on science. I firmly believe that more education and research needs to be accomplished.

First, thank you for opening doors to this discussion. In 2014, Rudolf Steiner Books published my book, An Electronic Silent Spring. It cited 200+ peer-reviewed studies about the biological effects of exposure to electromagnetic radiation (EMR) emitted by wireless devices and telecom infrastructure. First person accounts related to these studies. It reported the 1996 Telecom Act’s Section 704; the FCC’s definition of “harmful interference” (interference with existing broadcasts—NOT biology; FCC’s 2013 reclassifying the outer ear as an extremity so that mobile devices near it are allowed a Specific Absorption Rate of 4.0 W/kg, higher than the 1.6 W/kg allowed for non-extremities such as the head. Solutions included Whitney North Seymour’s amendment to Section 704. Dr. Gary Olhoeft advised me. He taught electrical engineering and geophysics at Colorado School of Mines for decades. In 2009, he got a deep brain stimulator (DBS) to ease his Parkinson’s symptoms—and experienced significant interference between his DBS and EMR-emitting devices. About 10% of Americans have a medical implant. Fewer than 0.5% of these devices have been tested in rigorous clinical trials. “Implantable Material and Device Regulation” Sept. 2021, Vol. 23, No. 9; E667-756, AMA Journal of Ethics. https://journalofethics.ama-assn.org/sites/joedb/files/2021-08/joe-2109_2.pdf How do EMR emissions from mobile phones, laptops, iPods, cellular antennas, smart utility meters, Wi-Fi, e-vehicles and transformers affect medical implants (deep brain stimulators, cardiac pacemakers, orthopedic devices, cochlear implants, continuous glucose monitors, insulin pumps) and people with implants? Here are a few related studies: Implanted medical devices in workers exposed to radio-frequency radiation (B. Hocking, 1991). How exposure to EMR may increase heat load and/or produce signal interference to orthopedic devices, cardiac pacemakers and cochlear implants. https://pubmed.ncbi.nlm.nih.gov/2047801/ A review of radiofrequency-induced heating challenge caused to medical implants during MRI procedures. AS Afolabi, 2025. J. of Eelctrical Systems and Information Technology. https://link.springer.com/article/10.1186/s43067-025-00264-3 Neurostimulators and Radiation Therapy: Is there any risk? H. Rida, 2025. Discusses safety guidelines in patients undergoing radiation therapy. https://www.sciencedirect.com/science/article/abs/pii/S1879850024002790 American Heart Association’s post about devices that may interfere with defibrilators and pacemakers. https://www.heart.org/en/health-topics/arrhythmia/prevention--treatment-of-arrhythmia/devices-that-may-interfere-with-icds-and-pacemakers Electromagnetic interference can lead a pacemaker to misread the heart’s beats. Prolonged or intense EMI can damage the pacemaker’s circuitry. https://forhearts.org/pacemakers-and-electromagnetic-interference-what-you-need-to-know/ I attach my book, its chapter 6 and testimony from Dr. Olhoeft and a woman with Type 1 diabetes. In creating discussion about the effects of EMR exposure, what are your goals? While everyone lives with laws that make environment (and health) considerations illegal, landlines are being eliminated, and more cell towers, smart meters, chromebooks and e-vehicles are deployed we need education about living with EMR exposure. We need to learn and respect nature’s cycles and to care for ourselves in EMR-saturated environments. We need forums that welcome questions; statutes that respect biological impacts; and opt-outs.

To whom is may concern, Im relieved at the thought that the impact of Cellular Infrastructure, EMF's, RF Radiation and Wireless Radiation could actually be studied and responded to. Our current laws do not protect us from what modern day technology is exposing us to and consequences of that concern me greatly! We want current research and property safety structures as well as the ability for small local communities and governments to have autonomy and the option to choose where we want to allow cell towers and small cell antennae. Our local board of supervisors has been sued for voting in favor of our community and siding with our concerns of a tower being 100 feet from family homes and close enough to fall on houses. This is awful for the people who live their lives and invest in their homes and community to be denied the right to choose not to have a 150' cell tower just feet from their homes. The fact that health and environmental concerns regarding these technologies cannot be used as evidence or argument to protect our families and environment is criminal. The FCC who benefits financially from these towers should not be in control of laws and regulations surrounding local governmental rights and the rights of a community to choose what we live with. Health effects from EMF's, RF Radiation and Wireless Radiation Exposure NEED to be studied by non-biased groups to that our health and safety can be protected, not profits of parties who benefit from this technology. It's time to protect our children, elders, animals and community as a whole. We don't ask to get rid of these technologies, but to understand their impacts so that we can make informed decisions that protect our safety while still providing people with needed modern technology. Health and safety is paramount!

To HHS, I experience symptoms such as headaches, heart racing, palpitations, irritability, and insomnia when exposed to wireless signals. I live in a shielded home with no wireless inside to help minimize exposure. I'm concerned that the United States has not adopted sufficiently precautionary policies to minimize public exposure to wireless radiation, particularly for people who report sensitivity. Other countries have demonstrated that stronger protective measures are possible. For example, France restricts the installation and use of wireless internet equipment in certain childcare settings and requires Wi-Fi in primary school classrooms to be switched off when not used for educational activities. Some European countries have also adopted stricter radio frequency exposure limits or additional protections for sensitive locations. I believe the United States should carefully examine these international approaches and consider stronger protections for public health. Section 704 of the Telecommunications Act of 1996 restricts local governments from regulating cell tower placement based on the environmental effects of compliant radio frequency emissions, and I disagree with that restriction. Communities should be able to consider health concerns when deciding where towers go. Thank you for your consideration. Dianna Suslo

Thank you for this opportunity to comment. I'm an attorney and I'll get straight to the point. As you may know, in the US, personal‑injury suits against telecom companies for harm from RF/EMF radiation have a very low success rate, and there is no well‑established "winning" strategy. The two walls that defeat most of these cases are (1) proving medical causation — courts require you to show your specific illness was caused by the radiation, and the US scientific record has not met that bar — and (2) federal preemption under Section 704 of the 1996 Telecommunications Act, which bars local/state regulation of towers based on health risk and has been used to preempt state tort claims. Government action is long overdue. There is much the HHS can do to help electromagnetic radiation (EMR) victims in the United States. To wit: 1. Upgrade the NTP carcinogen classification (biggest single lever) The National Toxicology Program (part of HHS) already found in 2018 that RF radiation is "reasonably anticipated to be a carcinogen" — the weakest tier in the Report on Carcinogens, based on a 10-year, ~3,000-animal rat study. If HHS upgraded this to "known" human carcinogen, it would: Give plaintiffs a federally endorsed causal finding to cite at summary judgment, directly attacking the #1 barrier (causation) Support failure-to-warn claims: if the government classified the hazard, defendants can't argue they "didn't know" Be hard for courts to ignore — federal agency findings carry substantial evidentiary weight 2. Fund and publish definitive human epidemiology NIEHS (NIH) could run or commission a large prospective cohort study of RF exposure and specific health outcomes. A published HHS finding of a dose-response relationship would be the strongest possible causation evidence. The current NIEHS position — "the probability that EMF exposure is truly a health hazard is currently small" — is what defense lawyers cite to kill cases. 3. FDA: set lower performance standards + require warnings FDA has authority under 21 CFR Part 1030 over RF-emitting electronic products. It could: Lower MPE limits below current FCC levels (which are based on thermal effects only, not non-thermal) Require warning labels on devices — this is critical because it converts a failure-to-warn theory from speculative to straightforward Require premarket chronic-exposure safety testing for new wireless technologies 4. CDC/ATSDR: issue a formal health advisory A CDC advisory stating that RF-EMF exposure is associated with specific health conditions would create a recognized standard of care that defendants deviated from. It would also give plaintiffs' medical experts a federal source to cite when opining on causation. 5. NIOSH: set occupational exposure limits NIOSH could issue recommended exposure limits for workers near towers and in wireless-intensive jobs. While advisory (OSHA enforces), these limits create a benchmark for what "reasonable" exposure looks like, supporting negligence claims. 6. Medical education and clinical guidelines HHS could direct that: EMF exposure history be taken as part of standard medical intake Clinical guidelines be developed for evaluating patients with RF-sensitivity symptoms Medical school curricula include EMF health effects This helps plaintiffs document their injury in a way courts currently find unconvincing (many plaintiffs' symptoms are dismissed as not medically recognized). The irony to note: Setting specific federal exposure limits could backfire by strengthening the implied preemption defense (courts argue that where the FCC has set a standard, state tort claims are displaced). The sweet spot for HHS would be to issue findings of harm and hazard classification without creating a new, detailed regulatory scheme that defendants can point to as "the FCC already regulated this." Bottom line: The single highest-impact action is upgrading the NTP carcinogen classification combined with FDA-mandated warning labels. Together, they attack both causation and failure-to-warn simultaneously, and they're within HHS's existing statutory authority. I have further thoughts regarding actions the HHS could take and legal strategy. If you'd like to follow up and continue the coversation please email emrlegal@protonmail.com

I am Robert J. Berg, the principal of the Law Office of Robert J. Berg PLLC. My law firm specializes in representing persons seeking the responsible siting of wireless communications facilities. Essentially, our clients oppose the placement of cell towers and other wireless facilities in residential neighborhoods, near schools, day care and senior centers, parks, ball fields, nursing homes, and similar areas where people live, recreate, or spend considerable time. Their concern primarily is that the health risks of non-consensual exposure to wireless radiation 24/7 are considerable and needs to be minimized or prevented if possible. Unfortunately, when Congress passed the Telecommunications Act of 1996, it acceded to industry's demand that State or local law is preempted if it denies a permit for the installation and operation of a wireless facility based on environmental concerns of the effect of wireless radiation exposure so long as the RF levels are within the FCC's RF emissions guidelines. Thus, federal law prevents our clients from raising health and environmental concerns when objecting to the siting of cell towers and other wireless facilities in their communities. Our clients then must rely on the FCC to be the guardian of their health with its RF emissions guidelines. Sadly, the FCC has refused to update its 1996 emissions guidelines despite many thousands of peer reviewed published scientific studies showing serious health and environmental impacts from exposure to wireless radiation from cell towers and cell phones and other wireless products. The FCC's 2019 decision to end its inquiry on a proposed rule-making inquiry to revise its 1996 guidelines was challenged in the DC Circuit, and the Court ruled that the FCC's decision, in large part, was arbitrary and capricious. The Court remanded the matter, in part, to address the questions posed by the Court and to reconsider the scientific literature. The FCC cannot be trusted. It has admitted that it has no expertise in the health, environmental, and medical issues. The FCC will need to rely on HHS's expertise. We are very fortunate that HHS is engaging in an analysis of the health issues relating to wireless radiation, and we applaud HHS for undertaking this important work. Thank you.